Further to our February update, Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act was introduced on February 9th. The Bill seeks to modernize the Canadian Environmental Protection Act, 1999 (CEPA) for the first time in twenty years and make related amendments to the Food and Drugs Act.
The Bill is now at the Second Reading stage in the Senate and CA has requested the opportunity to make a presentation when the bill comes to committee.
Overall, the Bill seems to be supported across industry sectors and welcomed by the NGO community although NGO’s have indicated that they will be seeking various amendments that could be problematic. As such, CA has begun an outreach campaign to provide Senators, key Ministers, and MPs with our member companies in their ridings, with a briefing document conveying our assessment and recommendations regarding the bill.
To summarize, Cosmetics Alliance Canada welcomes the modernization of CEPA as proposed and is offering the following two recommendations to Senators and Members of Parliament:
- Bill S-5 should be supported as proposed as the Bill achieves the goal of modernizing CEPA in a manner that will increase Canada’s effectiveness in protecting the health and environment of Canadians while providing for efficient administrative mechanisms including the ‘Best-Place Act’ approach. Additionally, Bill S-5 rests on a foundation of sound science and risk-assessment, all of which maintains Canada’s credibility and well-respected reputation in chemicals management that has grown over the past decade; and
- Given the complexity of the legislative framework, amendments should be avoided or at least carefully considered and supported by ALL stakeholders. The modernization of legislation that is as complex and far-reaching as CEPA, and which must be integrated with the equally complex Food and Drugs Act, is no easy undertaking. It requires a detailed understanding of both statutes as well as their administrative workings if unintended consequences or administrative roadblocks are to be avoided.
Given the significant input and policy advice already provided by stakeholders including industry, environmental organizations, representatives of vulnerable populations, and more – as well as the drafting of the Bill by experts in the details of the affected statutes – Cosmetics Alliance Canada is neither seeking nor offering our support for any amendments to Bill S-5 at this time.
As the practical implementation of CEPA depends on its regulations and accompanying guidance documents – which must be amended or developed following passage of the Bill through both the Senate and House of Commons – there will still be significant work ahead before any of the changes will be operative and affect industry.
CA will continue to collaborate with other industry sectors, the CEPA ICG, and our RIAS Technical Committee as the bill progresses. We will keep members informed of developments.
Bill S-5 CEPA Modernization – CAC Comments March 2022 – English
Bill S-5 CEPA Modernization – CAC Comments March 2022 – French
